State v. Myers, 2021 Ohio 475

In April 2019 Myers was involved in a high-speed flight from police that caused a multi-car crash, resulting in one death and several serious injuries; he was indicted on multiple felonies and misdemeanors.
Myers withdrew earlier not-guilty pleas and entered written and oral guilty pleas to counts 2–15; the state dismissed murder (count 1) at sentencing.
The parties jointly recommended consecutive prison terms producing an aggregate term of 25 to 27.5 years; the court accepted the plea and the joint recommendation.
During the Crim.R. 11 plea colloquy the court told Myers he had a right to “a trial,” and repeatedly explained the state would have to prove elements “to the unanimous satisfaction of a jury.”
At sentencing the court said it would “give the appropriate credit for time served,” but did not announce a days-total; the written entry later awarded 270 days of jail-time credit (April 12, 2019 – Jan. 6, 2020).
Myers appealed alleging: (1) the plea was invalid because the court failed to specifically tell him he was waiving his right to a jury trial, and (2) the court failed to calculate/announce jail-time credit at sentencing.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Myers)	Held
Whether the plea was invalid because the court did not expressly say Myers was waiving his right to a jury trial	The court reasonably and intelligibly informed Myers of the jury right by repeatedly stating the state would have to prove the elements "to the unanimous satisfaction of a jury"	The court failed to specifically advise Myers he was waiving his right to a jury trial, so the plea was not knowingly, intelligently, and voluntarily entered	Court affirmed: plea valid — totality of colloquy reasonably informed Myers of jury right despite not using the rote phrase "jury trial"
Whether the court erred by failing to determine and notify jail-time credit at the sentencing hearing	The court later calculated and included 270 days of credit in the sentencing entry; Myers did not challenge the amount	The court erred procedurally by not announcing the days-total at sentencing, denying a meaningful opportunity to object	Court affirmed: procedural noncompliance occurred but no plain error shown because Myers did not dispute the calculation and the entry included the credit; he retains post-sentencing remedies

State v. Veney, 120 Ohio St.3d 176 (Ohio 2008) (strict/literal compliance with Crim.R. 11(C)(2)(c) required for constitutional advisements)
State v. Ballard, 66 Ohio St.2d 473 (Ohio 1981) (Colloquy may be judged by totality; intelligible explanation suffices over rote recitation)
State v. Barker, 129 Ohio St.3d 472 (Ohio 2011) (Crim.R. 11 intended to give detailed instructions before accepting pleas)
State v. Engle, 74 Ohio St.3d 525 (Ohio 1996) (plea must be knowing, intelligent, and voluntary)
State v. Thompson, 147 Ohio St.3d 29 (Ohio 2016) (determination of jail-time credit affects substantial rights; statutory process for calculating and correcting credit)
McCarthy v. United States, 294 U.S. 458 (U.S. 1935) (‘‘matters of reality, not mere ritual’’ quote applied to plea colloquies)